Anti-Money Laundering Policy

1. Policy Statement

Marcellus Capital Group Limited ("Marcellus Bullion", "we", "our", "us") is committed to the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. We have zero tolerance for money laundering and terrorist financing, and we are committed to detecting, preventing, and reporting any suspicious activities.

This AML Policy sets out our approach to preventing the use of our services for money laundering, terrorist financing, or other financial crimes.

2. Legal Framework

Our AML programme is designed to comply with all applicable UK legislation and regulations, including:

• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended by the 2019 and 2022 Regulations)
• Proceeds of Crime Act 2002 (POCA)
• Terrorism Act 2000
• Terrorist Asset-Freezing etc. Act 2010
• Sanctions and Anti-Money Laundering Act 2018
• Criminal Finances Act 2017

We also take into account guidance from HMRC, the Joint Money Laundering Steering Group (JMLSG), and the Financial Action Task Force (FATF).

3. Money Laundering Reporting Officer (MLRO)

We have appointed a Money Laundering Reporting Officer (MLRO) who has overall responsibility for our AML programme. The MLRO is responsible for:

• Receiving and evaluating internal suspicious activity reports
• Making Suspicious Activity Reports (SARs) to the National Crime Agency (NCA)
• Ensuring AML policies and procedures are up to date and effective
• Providing AML training to all staff
• Liaising with law enforcement and regulatory authorities
• Maintaining records of all AML activities

4. Risk-Based Approach

We adopt a risk-based approach to AML compliance, which involves:

• Conducting a business-wide risk assessment to identify money laundering and terrorist financing risks
• Assessing the risks associated with each customer relationship
• Applying proportionate measures to manage and mitigate identified risks
• Regularly reviewing and updating our risk assessments

Higher-risk situations receive enhanced scrutiny and more intensive monitoring.

5. Customer Due Diligence

We conduct Customer Due Diligence (CDD) on all clients before establishing a business relationship. Our CDD procedures include:

• Identifying the customer and verifying their identity using reliable, independent sources
• Identifying beneficial owners and taking reasonable measures to verify their identity
• Understanding the purpose and intended nature of the business relationship
• Obtaining information on the source of funds

Please refer to our KYC/KYB Policy for detailed documentation requirements.

6. Enhanced Due Diligence

We apply Enhanced Due Diligence (EDD) in situations presenting a higher risk of money laundering or terrorist financing, including:

• Politically Exposed Persons (PEPs) and their family members/close associates
• Customers from high-risk third countries identified by the EU or FATF
• Complex or unusually large transactions
• Transactions with no apparent economic or lawful purpose
• Anonymous transactions or relationships

EDD measures may include obtaining additional documentation, more frequent reviews, senior management approval, and enhanced monitoring.

7. Transaction Monitoring

We conduct ongoing monitoring of all customer relationships and transactions to detect unusual or suspicious activity. Our monitoring includes:

• Scrutinising transactions to ensure they are consistent with the customer's known business profile
• Identifying transactions that are unusual in size, nature, or frequency
• Investigating transactions that appear to have no economic rationale
• Monitoring for structuring or layering activity
• Keeping customer information and documentation up to date

8. Suspicious Activity Reporting

Where we know or suspect, or have reasonable grounds for knowing or suspecting, that a person is engaged in money laundering or terrorist financing, we are required to make a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).

Red flags that may indicate suspicious activity include:

• Unusual transaction patterns or volumes
• Reluctance to provide required information or documentation
• Transactions inconsistent with the customer's known profile
• Large cash transactions or requests for cash payments
• Third-party payments without clear explanation
• Customers showing little interest in price or costs
• Rapid buying and selling of precious metals
• Requests to structure transactions to avoid reporting thresholds

All staff are required to report any suspicions internally to the MLRO. It is a criminal offence to "tip off" a customer that a SAR has been made.

9. Sanctions Compliance

We screen all customers and transactions against relevant sanctions lists and do not conduct business with sanctioned individuals, entities, or countries. We comply with:

• UK sanctions administered by HM Treasury's Office of Financial Sanctions Implementation (OFSI)
• United Nations Security Council sanctions
• EU sanctions (where applicable)

Any potential sanctions match will result in an immediate halt to the transaction pending investigation.

10. Staff Training

All staff receive regular AML training appropriate to their roles. Training covers:

• Legal obligations and potential penalties for non-compliance
• Recognition of suspicious activity and red flags
• Internal reporting procedures
• Customer due diligence requirements
• The prohibition on tipping off

Training records are maintained and staff competency is regularly assessed.

11. Record Keeping

We maintain records of:

• Customer identification and verification documentation
• All transaction records
• Risk assessments
• Internal suspicious activity reports
• Training records
• Correspondence with law enforcement

Records are retained for at least 5 years after the end of the business relationship or completion of the transaction, as required by law.

12. Policy Review

This AML Policy is reviewed at least annually, and more frequently if required by changes in legislation, regulations, or our business activities. The review considers:

• Changes in applicable laws and regulations
• Regulatory guidance and feedback
• Emerging money laundering typologies
• Internal audit findings
• Changes to our products, services, or customer base

13. Contact Information

For questions about our AML Policy or to report concerns, please contact: